Summary Judgment Motions
The Court requires strict compliance with Rule 56.1(f) which provides as follows:
Collateral motions in the summary judgment process, such as motions to strike, are disfavored. Any dispute regarding the admissibility or effect of evidence should be addressed in the briefs.
Motions for summary judgment and responses must comply with Local Rules 56.1(a) and 56.1(b), as well as the procedures outlined herein. The statements of undisputed material fact and responses shall be filed separately from the memoranda of law and shall include the line, paragraph, or page number where the supporting material may be found in the record. Courtesy copies of exhibits to summary judgment motions should be tabbed for easy access. The parties are to include only the relevant portions of any deposition cited to, including 2 pages before and 2 pages after the cite.
Failure to abide by the Local Rules may result in the Court striking briefs, disregarding statements of fact, deeming statements of fact admitted, or denying summary judgment. The movant shall not file more than 80 statements of undisputed material fact without prior leave of Court. The respondent shall be limited to 40 statements of undisputed material fact absent prior leave of the Court. In complex cases, the Court may request that the parties submit a timeline of events in addition to the statements of undisputed material fact.